Criminal Information — U.S. v. Carl Heinz Pierre (E.D. Va.)

Summary

A criminal information filed September 4, 2024 as Document 4 in United States v. Carl Heinz Pierre, Case No. 1:24-cr-173-PTG, in the U.S. District Court for the Eastern District of Virginia, Alexandria Division. Its single count charges conspiracy to commit bank fraud under 18 U.S.C. § 1349, alleging that from no later than about April 2020 through at least about June 2021 Pierre agreed with others to obtain funds from a financial institution by materially false and fraudulent pretenses, in violation of Title 18, United States Code, Section 1344. A forfeiture notice seeks property derived from proceeds of the offense and substitute assets. The information lists United States Attorney Jessica D. Aber and Assistant United States Attorneys Christopher J. Hood and Kristin Starr.

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Case 1:24-cr-00173-PTG Document 4 Filed 09/04/24 Page 1 of 2 PagelD# 7

a FILED
a IN OPEN COURT
IN THE UNITED STATES DISTRICT COURT O THE
EASTERN DISTRICT OF VIRGINIA] *
eae SEP - 4 2A
Alexandria Division
~ GLERK, U.S. DISTRICT COURT
UNITED STATES OF AMERICA ALEXANDRIA, VIRGINIA
V. Case No. 1:24-cr-173-PTG
CARL HEINZ PIERRE, Count 1: 18 U.S.C. § 1349

(Conspiracy to Commit Bank Fraud)
Defendant.

CRIMINAL INFORMATION

THE UNITED STATES ATTORNEY CHARGES THAT:

Count 1
(Conspiracy to Commit Bank Fraud)

1. Beginning no later than about April 2020, and continuing through at least about
June 2021, in the Eastern District of Virginia and elsewhere, Defendant, CARL HEINZ PIERRE,
did knowingly and intentionally combine, conspire, confederate, and agree with Raymond
Rahbar, Ryan Macaulay, and other persons known and unknown to the grand jury to devise a
scheme and artifice to defraud, and to obtain any monies, funds, credits, and assets owned by and
under the custody and control of a financial institution by means of materially false and
fraudulent pretenses, representations, and promises, in violation of Title 18, United States Code,
Section 1344.

(All in violation of Title 18, United States Code, Section 1349.)
Case 1:24-cr-00173-PTG Document 4 Filed 09/04/24 Page 2 of 2 PagelD# 8

Forfeiture Notice

Under Federal Rule of Criminal Procedure 32.2, the defendant is hereby notified that
upon conviction of the offenses charged in this Criminal Information, he shall forfeit to the
United States any property, real or personal, which constitutes or is derived from proceeds
traceable to the offense of conviction. The United States may also seek an order forfeiting
substitute assets if the proceeds of the offenses are not available.

(In accordance with Title 18, United States Code, Section 981(a)(1)(C); Title 21, United States
Code, Section 853(p); and Title 28, United States Code, Section 2461(c).)
Respectfully Submitted,

Jessica D. Aber
United States Attorney

» Cl

Christopher J. Hood
Kristin Starr
Assistant United States Attorneys


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